In re Skinner, 295 Ga. 217

In 2009 Skinner was retained for an uncontested divorce, received $900, and lost the client’s original paperwork; communication was sporadic and pleadings contained errors.
Client hired successor counsel in May 2010, requested the file and a $750 refund; Skinner refunded $650 but refused to release the file, claiming it was her work product.
The client posted negative online reviews; Skinner replied publicly and disclosed the client’s name, employer, payment amount, county of filing, and that the client had a boyfriend.
The State Bar charged violations of Georgia Rules of Professional Conduct 1.3, 1.4, 1.6, and 1.16; Skinner admitted a Rule 1.6 violation in a rejected petition for voluntary discipline.
The special master found violations of Rules 1.4 (failure to keep client informed) and 1.6 (improper disclosure of confidential information), but not Rules 1.3 or 1.16, and recommended a public reprimand with Law Practice Management consultation.
The Georgia Supreme Court adopted the recommendation: public reprimand and requirement to consult and implement State Bar Law Practice Management recommendations, citing mitigating and aggravating factors in discipline.

Issue	State Bar's Argument	Skinner's Argument	Held
Whether Skinner violated Rule 1.6 by posting client confidential information online	Posting client-identifying and confidential details online breached Rule 1.6	Disclosure was not substantially harmful; mitigating circumstances exist	Violated Rule 1.6; discipline imposed (public reprimand)
Whether Skinner violated Rule 1.4 by failing to keep client informed	Skinner failed to communicate from July–Oct 2009 and thereafter, violating Rule 1.4	Delays were related to personal/medical hardships and not willful neglect	Violated Rule 1.4; counted as misconduct but mitigated by circumstances
Whether Skinner violated Rule 1.3 (diligence)	Alleged delay, lost paperwork, and drafting errors evidenced lack of diligence	Errors/delay were not so extreme as to warrant a finding under Rule 1.3	No violation of Rule 1.3 found
Whether Skinner violated Rule 1.16 (duty to deliver file/refund unearned fees)	Refusal to deliver file and retention of disputed fees suggested Rule 1.16 violations	Returned $650; file contents were work product; no clear prejudice to client	No discipline under Rule 1.16: special master found no clear and convincing evidence of prejudice and the fee issue was moot after refund

In the Matter of Skinner, 292 Ga. 640 (740 SE2d 171) (rejecting initial petition for voluntary discipline)
In the Matter of Adams, 291 Ga. 173 (729 SE2d 313) (discipline/disposition guidance)
Swift, Currie, McGhee & Hiers v. Henry, 276 Ga. 571 (581 SE2d 37) (work-product and file possession principles)
Office of Lawyer Regulation v. Peshek, 334 Wis.2d 373 (798 NW2d 879) (comparison of discipline for multiple-client or more serious confidentiality breaches)